Cboe Global Markets

Conflict of Interest Management Policy

August 24, 2023
Cboe Japan Limited

1. Purpose

Pursuant to the provisions of Article 36, Paragraph 2 of the Financial Instruments and Exchange Act and Article 70-4, Paragraph 1, Item 3 of the Cabinet Office Ordinance on Financial Instruments Business, etc., the Company or its group companies (listed in 4 below) Group companies (hereinafter referred to as "group companies") that may unfairly harm the interests of trading participants who are our customers (hereinafter referred to as "conflict of interest transactions") ) will be identified and categorized by appropriate methods, and we will conduct business appropriately so as not to unfairly harm the interests of trading participants.

2. Types of Transactions That May Cause Conflicts of Interest

  1. Conflict of interest type
    1. Conflict of interest between the Company and a Trading Participant
    2. Conflict of interest between Trading Participants
  2. Competitive transaction type
    1. When the Company and a Trading Participant enter into a competitive relationship for the same subject
    2. In the event that trading participants of the Company compete with each other for the same subject
  3. Information-use type
    1. When the Company itself obtains profit by using information obtained through the relationship with the Trading Participant
    2. When other trading participants benefit from information obtained through our relationship with trading participants

3. Conflict of Interest Management System and Methods

The Company shall designate the Chief Internal Control Manager as the Conflict of Interest Manager, and shall centrally manage Subject Transactions that may occur within the Company by the following methods or a combination thereof:

  1. Blocking information between departments by installing information barriers
  2. Change of transaction terms and methods
  3. Suspension of one party's transaction
  4. Disclosure of conflicts of interest to trading participants or consent of trading participants
  5. Other methods deemed appropriate by the Conflict of Interest Management Department

4. Scope of companies subject to conflict of interest management

none